Searching Content indexed under Tax Authorities by Shearman & Sterling LLP ordered by Published Date Descending.
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The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems
In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules:
European Union
26 Aug 2019
IRS Guidance On Taxation Of Professional Team Trades
The Internal Revenue Service ("IRS") issued Revenue Procedure 2019-18 that provides a safe harbor provision for professional sports teams that allows a team to treat the value of a traded player,
United States
30 Apr 2019
IRS Announces Study Of Active Trade Or Business Requirement For Spin-Off Transactions
On September 25, 2018, the IRS announced that it is undertaking a study regarding the application of the five-year active trade or business requirement of Section 355(b) ...
United States
12 Oct 2018
Altera: Ninth Circuit Reverses US Tax Court And Holds That Treasury Regulation Allocating Stock-Based Compensation Expenses Is Valid
On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer ...
United States
3 Aug 2018
The European Commission Investigates U.K. Tax Rules
On October 26, 2017, the EC announced a formal State aid investigation into a U.K. exemption from U.K. anti-tax avoidance rules for certain transactions by multinational groups, the so-called Group Financing Exemption.
European Union
3 May 2018
Tax Court Rules Family Office Is Engaged In A Trade Or Business
On December 13, 2017, in Lender Management, LLC v. Commissioner, the U.S. Tax Court ruled that a family office, Lender Management, LLC ("Lender Management"), was "carrying on a trade or business"...
United States
15 Jan 2018
Renewable Energy Update: Effect Of The Tax Cuts And Jobs Act Of 2017
On December 19 and 20, 2017, both the House and the Senate passed the "Tax Cuts and Jobs Act of 2017" (H.R. 1) (the "Tax Reform Act"), which is expected to be signed by the President.
United States
27 Dec 2017
Tax Cuts And Jobs Act: House And Senate Pass Tax Reform Bill
On December 20, 2017, the House of Representatives and the Senate passed the "Tax Cuts and Jobs Act of 2017" (H.R. 1) (the "Bill").
United States
27 Dec 2017
House Passes Tax Cuts And Jobs Act: How The Senate Proposal Compares
On November 2, 2017, the House Ways and Means Committee (the "House Committee") released its plan for comprehensive tax reform: the "Tax Cuts and Jobs Act of 2017" ...
United States
24 Nov 2017
New Corporate Offences Of Failure To Prevent The Criminal Facilitation Of Tax Evasion
New Corporate Offences Of Failure To Prevent The Criminal Facilitation Of Tax Evasion.
17 Nov 2017
House Republican Tax Reform Bill Retains And Modifies Energy Credits
All of these provisions should have an effect on energy investments if the Tax Reform Bill is enacted in its current form.
United States
10 Nov 2017
IRS Expands Scope Of Spin-Off Private Letter Rulings In 18-Month Pilot Program
On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the "Pilot Program Rev. Proc.") that it is expanding the scope of spin-off private letter ruling requests that it will consider.
United States
2 Oct 2017
Personal Liability For Senior Accounting Officers Over Tax Accounting Arrangements— First Court Decision Provides A Cautionary Tale
The UK Senior Accounting Officer (SAO) regime was brought in by the Finance Act 2009 and requires large companies and groups to identify the individual who is responsible for certifying to the UK tax authority (HMRC) ...
1 Sep 2017
The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed On Sales Of Partnership Interests
The US Tax Court rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in a US business will not be treated as "effectively connected income"...
United States
18 Aug 2017
One-Year Delay To The Application Of Section 385 Documentation Rules
The documentation rules would have originally applied to debt instruments issued or deemed to be issued on or after January 1, 2018.
United States
15 Aug 2017
Notice 2017-42 Provides For One-Year Extension Of Existing Section 871(M) Rules
The New Notice extends the effective date for certain rules in those final regulations and extends the phase-in period provided last December, in Notice 2016-76 (the "2016 Notice")...
United States
11 Aug 2017
Update On US Federal Tax Reform Proposals And Their Effect On The Renewable Energy Industry
While tax reform has been a stated focus of the Trump administration and Congress, details remain elusive.
United States
25 May 2017
Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings On Certain Spin-Off Debt Exchanges
The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation's transfer of stock or securities of a controlled corporation...
United States
18 May 2017
Potential US Tax Reform Could Fundamentally Change The Structure Of The US Tax System
With the election of Donald Trump, who pledged during the campaign to usher in fundamental tax reform, the Republican majorities in Congress have begun planning major tax changes...
United States
30 Nov 2016
Highly-Anticipated Final Regulations On Related-Party Debt Instruments Issued
On October 13, 2016, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 385 of the Internal Revenue Code...
United States
22 Oct 2016
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